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Wednesday, February 20, 2013

ACC ASP Press Release

I got a nice email from Scott Jenson, Director of Issues
Communication, American Chemistry Council, providing me with a copy of the press
release about their CFATS Alternative Security Program. Reader’s will
remember my detailed
review of this template for submitting the information necessary for ISCD
to evaluate a facility site security plan.

ISCD Endorsement

I’ve been a little disappointed that ACC hasn’t been a more
proactive in publicizing this outstanding tool. Reading this press release it
is clear to see why Scott and his people have held off. In the press release
there is a link to a very kind letter from David Wulf, Director, Infrastructure
Security Compliance Division, essentially endorsing the ACC ASP. David says, in
part:

“Thank you especially for ACC's efforts
to help high - risk chemical facilities meet the CFATS requirements through the
development of the ACC Alternative Security Program ( ASP) Guidelines and
Template . We commend your decision to make these documents available to all
facilities regulated under CFATS for potential consideration and reference in
the development of other ASPs.”

There is no date on the Wulf letter, but I’m assuming that
as soon as ACC had this letter in hand, they started immediate work on this
press release. This is a very valuable endorsement. I would like to join David
in commending ACC for sharing this tool with the whole of the regulated
community, not just their member organizations.

BTW: It would be
nice to see some mention of this ASP somewhere on the DHS
Chemical Security web page. A mention of the ACC ASP with a link to the
document would make it easier for non-ACC members to avail themselves of this
tool.

ISCD Promises Better
SSP Performance

David takes the opportunity in this letter to address the
continued slow pace of SSP approvals. He notes that ISCD has streamlined the
authorizing and approval process and then reports that ISCD has set “set a goal
of 400
approvals [emphasis added] by the end of 2013”. This would be a truly
remarkable accomplishment since the last official number that I had seen on
approvals was that only 2 had been completed. Even at this rate they will only
have about 1/3 of the SSPs approved before they have to go back and start
re-evaluating SSPs that were previously approved.

Actually, ISCD has not approved any SSPs yet. They have only
given provisional approvals because facilities can still not comply with the
Terrorist Screening Database vetting requirements of Risk-Based
Performance Standard 12. Metric 12.4 for all four Tier levels states that:

“Processes are in place to provide
DHS with the necessary information to allow DHS to screen individuals (e.g.,
employees, contractors, unescorted visitors) who have access to restricted
areas or critical assets against the TSDB.”

Since ISCD has not yet even published their proposed
procedures for this vetting process, facilities are not able to comply with
this requirement. ISCD is over four months late (based upon a promise made by
Undersecretary Beers in
testimony to a Congressional Committee) in the publication of the 60-day
information collection request (ICR) in the Federal Register. If this were to
be published today it would still be nearly the end of the year (best case)
before final OMB approval could be given to begin the collection of the
information necessary for this vetting.

So it will be nearly impossible for ISCD to achieve their
goal of 400 approvals by the end of the year. I’m all for setting high goals
David, but they must be achievable.

About Me

I spent 15 years in the US Army as an Infantry NCO. After getting out of the Army I started working in the chemical industry, getting my BSc Chemistry degree while working as a technician. I spent 12 years working as a process chemist in a specialty chemical company. Most recently I worked as a QA/R&D Manager in a specialty chemical manufacturing facility. Currently I am working as a freelance writer.